1 ANTI‐CORRUPTION AND ANTI‐BRIBERY POLICY Guidelines for Compliance with Canada’s Corruption of Foreign Public Officials Act and US Foreign Corrupt Practices Act, 1. OBJECTIVE OF THE POLICY CGX Energy Inc. (the “Company” or “CGX”) is committed to conducting its business in accordance with applicable law and the highest ethical standards. That commitment is reflected in our Code of Business Conduct and Ethics and in this Anti‐Corruption and Anti‐Bribery Policy (the "Policy"), which is intended to provide guidance and procedures for compliance with Canada's Corruption of Foreign Public Officials Act ("CFPOA") and the US Foreign Corrupt Practices Act, the Guyana Anti‐money Laundering and countering the financing of terrorism Act 2009 and other related anti‐corruption laws, rules and regulations including but not limited to the Canadian“ Extractive Sector Transparency Measures Act “ (ESTMA ). There are laws throughout the world combating bribery and corruption, particularly with respect to government officials, including laws that apply to CGX’s international activities. Three such laws are the CFPOA, FCPA and UKBA. Although the CFPOA and FCPA are laws of Canada and the United States respectively, such laws can apply to CGX anywhere in the world. Additionally, CGX’s international activities may be subject to local anti‐bribery and anti‐corruption laws including the Guyana Anti‐money Laundering and countering the financing of terrorism Act 2009 and any applicable amendments CGX is committed to compliance with anti‐bribery and anti‐corruption laws. The Compliance with Anti‐ Corruption and Anti Bribery laws is intended to ensure that that CGX and all of its subsidiaries (collectively “CGX” or the “Company) does not seek or receive any improper advantage in the course of its business dealings and to ensure that all payments an expenses are properly recorded in our books and records. 2. COMPLIANCE AND REPORTING This Policy applies to every CGX employee, including but not limited to senior executive and financial officers, and to members of the Board of Directors and reflects the standards to which CGX expects all people and entities providing work or services for CGX to adhere to. All Agents, suppliers, consultants and other providers of goods and/or services (collectively, “Contractors”) entering into agreements or arrangements with CGX entities are also required to comply with this policy as if they were CGX’s employees in the course of their provision of goods and/ or services to CGX or at CGX’s discretion, to have and comply with their policy, which shall be appropriate in the circumstances. Employees and Contractors are required to take all responsible steps to prevent a violation of this Policy, to identify and raise potential issues as soon as reasonably practicable, and to seek additional guidance when necessary. CGX Personnel who have any questions about this Policy are asked to contact CGX’s Chief Financial Officer (the “CFO”), or any of the officers of the Company. Suspected violations of this Policy may be reported to CGX’s CFO or CEO OR Executive Chairman or Audit Committee Chair.
ANTI�CORRUPTION AND ANTI�BRIBERY POLICY
Jul 06, 2023
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